The Cybersecurity Maturity Model Certification (CMMC) has been discussed and debated at length. With so many different opinions, it’s challenging to know what you should be doing to comply with its guidelines and requirements.
This CMMC compliance guide will provide an overview of the most critical aspects of CMMC and then offer some practical guidance for your organization.
What is CMMC Compliance?
CMMC is a certification that the U.S. Department of Defense (DoD) requires for businesses that work with the federal government and handle Controlled Unclassified Information (CUI). A CMMC certification helps ensure your organization has the right cybersecurity policies and procedures to protect sensitive data from being hacked or lost. It also ensures you meet compliance requirements set forth by federal agencies such as NASA and the DHS Cyber Security Division.
The CMMC program requires a contractor to undergo an audit and be assessed against a series of cybersecurity best practices. Below are seven things you should know about CMMC.
1. Going Through the CMMC Compliance Process Requires Resources
The CMMC assessment and certification is a slow and gradual process that cannot just be completed overnight. It requires a lot of work and resources from your organization. You can’t simply hire a third-party to complete the process for you.
The CMMC compliance process can take months or even years, depending on your organization’s size and scope. This commitment requires patience and long-term investment from your company and its stakeholders.
2. Compliance Must Be Maintained for The Duration of the Contract
This is because lapses can result in fines or loss of business opportunities. If a contract lasts for two years, then your organization must keep up with all the security guidelines of the CMMC until the end of the contract. If your organization is found to be non-compliant during an audit, then your organization might be penalized.
However, it must be noted that failing an audit is not exactly a death sentence. If you fail the audit, don’t panic. It doesn’t mean your contract with the government is over right away; however, you need to take corrective action and pass the audit next time.
A certified third-party assessor, or the C3PAO, will work with you on finding solutions to your problems and help you pass the audit so that the government can continue working with you. You won’t be disqualified from future contracts because of a failed audit, but you do have to make adjustments.
3. Compliance Relies on Audits Made by Third Parties
Companies that desire to be CMMC-compliant have to undergo a third-party audit of their cybersecurity practices. This is where the C3PAO comes in. These third-party auditors will conduct interviews with employees, review documentation, and conduct on-site assessments. Auditors also help companies identify weaknesses in their systems and work towards improving them before external regulators find out about them.
4. CMMC Compliance Covers three Levels of Cyber Maturity
Recently, CMMC 1.0 has been replaced by CMMC 2.0, with the reduction of levels from five to three as the main change. Now, the CMMC covers three levels of cyber maturity (L1 to L3), with L1 being the most basic stage of compliance. The higher the level, the more sophisticated the cyber security measures and requirements are.
The following are the three levels of CMMC compliance you should be familiar with:
- Level 1 (Foundational): This is the lowest level of compliance for CMMC 2.0, and it consists of 17 basic cyber security practices, including the implementation of basic Access Controls and Identity and Authentication. At this stage, your organization should focus on safeguarding Federal Contract Information (FCI). This refers to data that shouldn’t be publicly released but that’s provided for the government under an agreement to develop a product or service for the government. This excludes information provided by the government to the public, such as public websites and transactional information. Unlike the other levels, Level 1 doesn’t need a third-party assessment, as it doesn’t involve more confidential data, like sensitive natural security information.
- Level 2 (Advanced): This level goes further in tightening the overall security practices of your organization. At this stage, your organization’s primary objective is to protect Controlled Unclassified Information (CUI). It refers to government-owned information that necessitates dissemination controls or safeguarding that’s in accordance with applicable laws and government-wide policies. By complying with Level 2, you would be able to give the DoD assurance that your organization has the ability to provide adequate protection for CUI.
- Level 3 (Expert): This level is essentially the combined levels 4 and 5 of the CMMC 1.0. At this stage, your organization should pay attention to reducing the risk and improving the effectiveness of safeguarding CUI against Advanced Persistent Threats (APTs). This means Level 3 mandates your organization to check and measure your security controls over time to know how effective they are and to provide corrective action whenever necessary.
Compliance with CMMC requires serious consideration of the levels mentioned above. However, it’s important to note that leveling up is not required for all organizations. As long as your company can meet the standards stated in the contract, then it’s good to go.
5. Companies That Handle Sensitive Data Will Also Need to Comply With CMMC
Private partners and contractors of the DoD are not the only ones that need to comply with CMMC. Companies that handle sensitive data will need to comply with CMMC as well.
Sensitive data includes a wide range of information, including financial details such as credit card numbers, bank account numbers, and Social Security Numbers. It also includes health care information like medical records, health insurance claims, biometric data, passwords, or other unique identifying characteristics (such as fingerprints).
6. CMMC Compliance Can Help Level the Playing Field in the Public Sector
When you think of government contracts and cybersecurity, two things come to mind: red team alerts and companies that are favored over others. Red team alerts are when a government agency gives a contract to a company that has lower security standards than another company that might have better cybersecurity practices. This means smaller businesses can’t compete with larger ones because they don’t have enough resources or money to meet the requirements set by the agency and other laws.
But with CMMC compliance, all companies can compete on equal terms—they simply have different levels of Risk Mitigation Strategies (RMS) set up for them depending on how much money they want to spend on cybersecurity measures.
7. CMMC Doesn’t Mean You’re Compliant with Other Security Standards
You can be CMMC-certified and not ISO 27001 compliant, or vice versa. CMMC is a set of cybersecurity practices, while ISO 27001 develops its own set of international standards. Compliance with one doesn’t mean you’re automatically compliant with the other.
If your organization is planning to work with the government and handle sensitive or classified information, then it’s best to prepare the necessary tools, documents, and processes that you need to implement under the requirements and guidelines set by the CMMC
Remember that to be compliant, your organization must have a plan and follow it. You also need to ensure your employees are aware of the policies so they can stay vigilant and take appropriate action in case of a possible breach.